IR 05000206/1982019
| ML20058D240 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 07/07/1982 |
| From: | Book H, Wenslawski F, Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20058D219 | List: |
| References | |
| 50-206-82-19, NUDOCS 8207270056 | |
| Download: ML20058D240 (13) | |
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U.S. NUCLEAR REGULATORY COMMISSION
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REGION V
Report No.
50-206/82-19
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Docket No.
50-206 License No.
DP!t-13 Safeguards Group Licensee:
Southern California Edison Company P. O. Box 800, 2244 Walnut Grove Avenue Rosemead, California 91770 Facility Name:
San Dnofre Unit 1 Inspection at:
San Clemente, California Inspection conducted:
June 14-18, 1982 and Subsequent Telephone Conversation on June 25, 1982 7bk2 Inspector:
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G. P. Yuhas, Radiation Specialist Dite' Signed Approved by:
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F. A. Wens'lawski, Chief, Reactor Radiation Protection-Dafe signed Section Approved by:
H. E. Book, Chief, Radiological Safety Branch Date Signed Summary:
Inspection on June 14-18, 1982 and Subsequent Telephone Communication on June 25, 1982 (Report No. 50-206/82-19)
Areas Inspected:
Routine unannounced inspection of transportation activities as they pertain to the processes of receipt, packaging, transfer, delivery to a carrier, and transport of radioactive materials.
Licensee action on previous inspection findings, and Licensee Event Report No.82-013 were also reviewed.
The inspection involved 42 hours4.861111e-4 days <br />0.0117 hours <br />6.944444e-5 weeks <br />1.5981e-5 months <br /> onsite by a regionally based inspector.
Results: Of the three areas inspected, one apparent item of noncompliance was identified (failure to post a high radiation area,10 CFR 20.203(c)(1), paragraph 3).
8207270056 820707 PDR ADOCK 05000206 G
PDR RV form 219(2)
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DETAILS
1.
Persons Contacted
- W. Moody, Deputy Station Manager
- P. Knapp, Manager, Health Physics
- B. Katz, Station Technical Manager
- F. Briggs, Compliance Engineering
- D. Duran, Radwaste Supervisor
- E. Medling, Health Physics Supervisor, Unit 1 J
- J. Dunn, Project Quality Assurance Supervisor
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- D. Helm, Radwaste Foreman
- E. Bennett, Health Physics Foreman
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K. Brooks, Dosimetry Foreman C. Hansen, Radwaste Technician P. Serra, Radwaste Technician
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- Indicates those individuals attending the exit interview on June 18, 1982.
In addition to the individuals noted above, the inspector met with
and held discussions with other members of the licensee's and contractor's staffs.
2.
Licensee Event Report (LER)
LER No. 82-13.
In reports dated May 19, June 1, and June 11, 1982,
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the licensee reported that a Quality Assurance audit identified that on Detober 2,1981 during a radioactive liquid release, the midpoint and endpoint samples required by section 4.5.D.(2) of the
Technical Specifications (TS) were not collected.
The release made i
pursuant to Liquid Radioactive Release Permit No.1096 consisted of approximately 10,000 gallons of slightly contaminated water from the reheater pit sump. The total activity released was reported as
1.28 E-3 curies. The concentration released was a very small fraction of the values permitted by 10 CFR 20, Appendix B.
Failure to collect samples required by TS Section 4.5.D.(2) would normally be classified as a Severity Level V item of noncompliance.
However, since the licensee identified the failure, reported it as required by TS Appendix B Section 5.6.3.a.(1), implemented timely
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initial corrective action, and proposed a reasonable schedule for further corrective action to prevent recurrence, no item of non-
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compliance will be cited pursuant to 10 CFR 22, Appendix C, para-
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graph IV.A.
LER No. 82-17. On June 14, 1982, the inspector was advised by the
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Senior Resident Inspector that between 12:01 a.m. June 13 and 2:10 a.m. June 14, 1982, the pressure in the South Waste Gas Decay Tank (SWGDT) decreased from 25 psig to 1 psig.
On the evening of
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-2-June 14, during a tour of the restricted area, the inspector reviewed the operational status of the stack monitoring equipment and discussed the observed decrease in SWGDT pressure with licensee representatives. The stack gas monitor R-1214 and the multipoint recorder RLR-1200 were operable during the period in question.
According to the Shift Supervisor, review of RLR-1200 data did not indicate a release associated with the pressure decrease.
The inspector observed that the vacuum gauge for R-1221, Stack Iodine Monitor, appeared to have failed and the flow meter was not respond-ing in its characteristic manner.
The inspector informed the Shift Supervisor of this observation.
The Shift Supervisor confirmed the loss of flow curcuit for R-1221 was not operable.
From discussions with the Shift Supervisor, the inspector was informed that the
. licensee does not understand Technical Specification 4.6 to require continuous sampling of the stack for particulate and iodine activity.
This position was confirmed by the Chemistry Supervisor. The inspector advised the licensee that he understood Technical Specification 4.6 to require sampling of the stack for particulate and iodine activity whenever radioactive materials are released via the stack pathway. This matter was discussed at the Exit Interview.
On the morning of June 15, 1982, the inspector and Chemistry Foreman physically verified the operability of R-1221. Two Main-tenance Orders, M0-S13523 and M0-S13524, had been issued to investi-gate the loss of flow signal for R-1221 and correct a filter paper drive malfunction on R-1220. At 9:30 a.m. on June 15, 1982, the licensee formally informed the inspector and resident inspector pursuant to Technical Specification, Appendix B, section 5.6.3.a.2 of the apparent unplanned release of the SWGDT.
Based on initial review of the licensee's data, it appeared the potential release consisted of about 1 millicurie of Kr-85. The inspector will review the licensee's follow-up report and investigation of this matter at a later date.
3.
Licensee Action on Previous Inspection Findings (Closed)(50-206/IC 80-14) IE Circular No. 80-14, " Radioactive Contamination of Plant Demineralized Water System and Resultant Internal Contamination of Personnel."
Review of an August 27, 1981 memorandum for file indicates the licensee received, reviewed, and took appropriate actions to preclude recurrence of the situations described in the circular.
(Closed)(50-206/IC 81-09) IE Circular No. 81-09, " Containment Effluent Water that Bypasses Radioactivity Monitor." Review of a February 10, 1982 memorandum indicates the licensee received and performed an appropriate review of their facility in view of the circular's subject matte.
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-3-(Cl osed)(50-206/82-03-01) Noncompliance, failure to follow radia-tion protection procedure SPRP-008.
In the licensee's March 23, 1932 response to the Notice of Violation, they stated that Health Physics Procedure S01-VII-4.2, " Bioassay Program," would be revised and contractors would be instructed to assure that all workers '
assigned in the restricted area receive a termination whole body count.
Review of 50123-VII-4.2, " Bioassay Program," Revision 1, dated April 26, 1982, indicated that appropriate revisions were made.
In reviewing the procedure, the inspector noted that the 40 MPC uptake values listed in step 6.8.6 did not appear consistent with those values calculated in accordance with 10 CFR 20.103 methodology.
The responsible engineer stated that although their values were conservative, a revision of the procedure was being processed.
Review of Purchase Order 8A032941 indicated that
"boilerplate" had been added to those contracts involving work in the restricted area to assure that the contractor is responsible to present workers for exit whole body counts.
The inspector had no further questions regarding this matter.
( Closed)(50-206/82-09-02) Unresolved Item, involving potential exposure in excess of 1.25 Rem per quarter without determination of previous occupational dose.
This finding, made by the licensee during a quality assurance audit, was documented as Corrective Action Request (CAR) S01-P-484.
Review of the licensee's response indicates that none of the three individuals cited actually violated the conditions of 10 CFR 20.101(a).
In following up on this matter, the licensee selected 62 individuals from a field of 616 and performed a comprehensive review that verified compliance with 10 CFR 20.101(a).
Additionally, the licensee plans to strengthen their administrative controls by revision of procedure S0123-VII-4.6,
" Radiation Exposure Standards," to more clearly address the regula-tory requirement.
(0 pen)(50-206/82-09-01) Inspector identified item involving control f
of access to high radiation areas. On March 11, 1982, the licensee offered a commitment to develop a high radiation area access control procedure within 90 days. On March 17, 1982, the Health Physics Supervisor, Unit 1, issued a memorandum implementing interim measures to improve access control until the procedure is established.
Review of the Health Physics Foreman's log, inventory of high radiation area lock keys, and physical inspection of locked high radiation areas, indicated the interim controls were being implemented. A procedure, 50123-VII-7.4, " Posting and Access Control," has been drafted.
The licensee representative stated, during the exit interview, that this procedure will complete the review process and be implemented by June 30, 1982.
On June 14, 1982, at about 4:45 p.m. during a tour of the contain-ment sphere, the stairway near the "C" steam generator leading from the 22' to the 19' elevation was barricaded with a rope and posted
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-4-with a sign bearing the radiation caution sumbol and the words:
" Caution, Radiation Aren." Affixed to the sign was a 2" smear patch with a dose rate of 150 mr/hr recorded. At the 19' elevation, a rope barricade posted with a " Caution, Radiation Area" sign and a dose rate of 80 mr/hr was annotated.
A survey of the area by the inspector using a portable ion chamber (Eberline RD-2, NRC-008985, calibration due June 22, 1982) found whole body dose rates up to 150 mrem /hr in accessible areas on the stairway and platform in close proximity to the steam generator.
The licensee representative, using two portable survey instruments (R0-2, Serial No.1236, calibration due August 11,1982; RD-3A, Serial No. 486, calibration due September 2,1982), confirmed the dose rate of 150 mrem /hr.
10 CFR 20.202(b)(3) defines "high radiation area" as any area accessible to ' personnel in which there exists radiation levels such that a major portion of the body could receive in any one hour a dose in excess of 100 mrem.
10 CFR 20.203(c)(1) states:
"Each high radiation area shall be conspicuously posted with a sign or signs bearing the radiation caution symbol and the words:
" Caution,
The licensee representative took immediate action to have the area near the "C" steam generator posted as a "High Radiation Area."
Two other observations regarding posting of high radiation areas were also brought to the licensee's attention.
The walkway near the "B" steam generator had dose rates of
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110 mrem /hr; however, the rope barricade and "High Radiation Area" sign placed parallel to the walkway did not clearly inform the worker that the walkway itself was a high radiation area.
At one location on the 22' elevation, the "High Radiation
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Area" signs had been placed in the overhead above the walkway.
The inspector had to be informed of this sign since it was not obvious during the tour.
These observations were discussed in terms of need for posting to be " conspicuous."
10 CFR 19.12 requires in part that workers be kept informed of radiation in portions of the restricted area. The licensee frequently uses the phrases, "see posted surveys" or "see current surveys" on the Radiation Exposure Permits (REP).
During this tour, the inspector noted the posted survey board for the 10' elevation was not at the entrance to containment and that the high radiation area
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-5-near the "C" steam generator was not identified on either the survey board or in the current surveys on file at the containment entrance.
The Health Physics Manager stated that as an interim measure, copies of applicable surveys will be attached to the REPS, and health physics technicians were reinstructed in their responsi-bilities to keep workers informed of radiation levels.
Failure to post the area around the "C" steam generator as a "High Radiation Area" represents noncompliance with 10 CFR 20.203(c)
(50-206/ 82-19-01).
4.
Transportation Activities a.
Management Controls Some changes in the management control of transportation activities have been made since the last inspection (Inspec-tion Report No. 50-206/81-11).
Station Order (S0) S-E-205 has been deleted. S01-E-218, " Control of Radioactive Material,"
and S0123-HP-1, " Organization and Responsibilities of the Health Physics Section," have been implemented.
Review of these procedures indicate that the Health Physics Manager, through the Radwaste Supervisor, has overall responsibility for the " Solid Radioactive Waste Program."
Neither procedure specifically references 10 CFR 71.
10 CFR 71, Appendix E, criterion 1, states in part that the authority and duties of persons performing activities affec-ting safety-related functions shall be clearly established and delineated in writing.
From discussions with the Radwaste Foreman and two radwaste technicians, the inspector was informed that they were unaware of where their duties and responsibilities are set out in writing.
The Radwaste Super-visor presented written budget proposals which listed the foremens' and technicians' responsibilities.
Failure of S01-E-218 and S0123-HP-1 to specifically reference 10 CFR 71, and the apparent failure of the foreman and tech-
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nicians to be aware of their written duties and responsibilities was brought to the licensee's attention at the exit interview.
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Since the last inspection, the procedures listed below have either been issued or revised.
These procedures were reviewed to determine if they have been developed consistent with the requirements of Technical Specification 6.8,10 CFR' 30, 10 CFR 71, 49 CFR 100-199, and the burial site criterio _
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-6-Procedure No.
Title Revision No.
S0123-HP-1 Organization and Responsibilities of the Health Physics Section
S01-E-218 Control of Radioactive Material
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S01-VI I-8.1 Solid Radioactive Waste Packaging, Labeling, and Shipping
S01-VII-8.2 Shipment of Radioactive Material
S-A-126 Personnel Training
Based on review of these procedures and follow-up on previous procedure development comments expressed in paragraph 3(a) of Inspection Report No. 50-206/81-11, the following observations were brought to the licensee's attention:
The licensee corrected observations 1 and 3 of paragraph 3(a)
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in Inspection Report No. 50-206/81-11.
Section 6.5.2.6 of S01-VII-8.2 does not include the
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burial site criterion expressed in WN-IO19, Item 26, that absorbed oils must be placed in at least a "4 mil plastic liner" sealed, then placed in a metal container.
The procedures do not yet address 10 CFR 71.5a.
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Station Order S-A-126, " Personnel Training," Revision 8, did not affect paragraph XIV, " Low Level Radioactive Waste Packaging and Shipping Training."
The inspector verified by direct observation that the Radwaste Supervisor had immediately available up-to-date copies of 49 CFR, Parts 100-199, and a State of Washington License No. WN-IO19-2. Up-to-date copies of 10 CFR 20, 30, and 71 were available onsite; however, the Radwaste Supervisor had been furnished a bound copy dated January 1,1981.
Prior to
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completion of the inspection, the Radwaste Supervisor stated that three copies of the loose leaf updated versions of Chapter 10 of the Code of Federal Regulations would be provided for his use.
No changes in the licensee's Quality Assurance Plan involving 10 CFR 71, Appendix E, have been made since the last inspection.
No items of noncompliance or deviations were identified in this area.
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-7-b.
Implementation Based on review of Section D, "Radwaste Shipments," of the licensee's Semi-Annual Effluent Release Reports, the following findings were brought to the licensee's attention.
Technical Specification, Appendix B, paragraph 5.6.2.a
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states that the format of USNRC Regulatory Guide 1.21 will be used for reporting purposes. S01-VII-8.1.1, " Solid Waste Records and Reports," also clearly presents the Regulatcry Guide 1.21 format to be used.
However, both the first and second half 1981 reports were not consistent with the suggested format.
Review of the second half 1981 solid waste report data
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was compared to the " Radioactive Material Shipment Records" (RMSR) and found to be in agreement.
From review of the RMSR data, and from discussions with the licensee, the following NRC certified packages were used during the period May 1981 through June 1982.
NRC Certificate of Compliance No.
Model No.
USA /6144/B B-2 USA /6601/B LL-50-100 USA /9080/A HN-600 USA /9094/A CNSI-14-195H The inspector verified that the licensee had registered to use each package as required by 10 CFR 71.12(b)(1)(iii) and had onsite an up-to-date copy of each Certificate of Compliance and referenced material as required by 10 CFR 71.12(b)(1)(1).
Most of the licensee's shipments of radioactive material met the Low Specific Activity (LSA) criterion of 10 CFR 71.4(g).
The packaging used consisted of new 17H drums (P.O. No. 81821909, July 14,1981) and strong tight wood or steel boxes.
No spent nuclear fuel was shipped during the period of review; therefore, no effort was made to review the licensee's program for transfer of spent fuel during this inspection.
No items of noncompliance or deviations were identified in this area.
c.
Preparation of Packages for Shipment The inspector verified by record review that the licensee has written procedures to insure that certified packages are
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-8-inspected prior to use, and are loaded and closed as required by 10 CFR 71.12(b)(1)(ii).
The " Inspection Planning Data Reports" for the following shipments were reviewed:
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Identification No.
Date Package SW 81 74 June 16,1981 USA /9094/A SW 81 84 July 9, 1981 USA /9094/A GA 81 2 July 2, 1981 USA /6601/B SW 82 5A June 5, 1982 USA /9030/A The licensee utilizes a broker to package much of their radioactive waste.
The broker representative has onsite
written procedures for loading and closing packages.
These
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procedures. included burial site criteria such as those in-volving proper containment of absorbed oil.
During tours of the R.E.D. Building on June 14, 1982, no i
packaging of radioactive waste was in progress. No packages prepared for delivery to a carrier were available for opening
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or inspection.
No items of noncompliance or deviations were identified.
d.
Delivery of Packages to a Carrier Records of the following shipments were reviewed to determine compliance with 10 CFR 71.5, 49 CFR 172,173, and 10 CFR 30.41.
Identification No.
Date SW-81-74 June 16,~1981'
SW-81-84 July 9,1981 SW-81-85 July 24, 1981
SW-81-86 August 3, 1981 SW-81-90 October 26, 1981
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GA-81-1 June 26,1981 GA-81-2 July 2, 1931 C- 01-82 March 9, 1982 S-11-82 March 10,1982
S-12-82 March 11, 1982 S-24-82 June 2, 1982
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S-Canada-1 January 8, 1982 Specific records reviewed included as appropriate:
Radioactive Shipment Checkoff Sheet
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Bill of Lading
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Washington State Certification
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SONGS Radioactive Material Shipment Record
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Radiation / Contamination Survey Data
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Inspection Planning Data Report, Closure
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U.S. Ecology, Radioactive Waste Shipment and Disposal
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Instruction to Carrier for Maintenance of Exclusive Use
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of Shipment Controls Based on this review, the following observations were brought to the licensee's attention:
S-Canada-1 involved return of a device containing one
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curie of tritium in the form of a fixed dry solid oxide (painted surface) to the manufacturer. Survey records indicate the strong tight package was smeared for loose surface contamination.
The smears were analyzed on a BC-4 (pancake type, GM detector with a 1-2 mg/cm2 window thickness) counter.
The BC-4 counter is appropriate for measuring most radioisotopes associated with power reactors; however, it is not designed to measure the low energy beta emitted from tritium. This instrument is not appropriate to analyze for loose surface tritium con-tamination.
The " Shipper's Certification" on the Straight Bill of Lading
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was not signed on S-11-82 and S-12-82.
An identical signed certification appears on the SONGS Radioactive Material Shipment Record (RMSR).
The Radwaste Foreman stated that a copy of the RMSR had been provided to the driver.
The Radiation / Contamination Survey Data record for S-24-82 had
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not been signed off as having been reviewed.
Considerable effort was necessary for the Radwaste Foreman to address questions regarding the survey data.
No items of noncompliance were identified in this area.
e.
Receipt of Shipments During a tour of the Shipping / Receiving portion of the Ware-house on June 16, 1982, the inspector observed a conspicuous sign alerting the warehouseman to immediately notify " Health Physics" on receipt of radioactive material. The warehouseman was familiar with his responsibility involving receipt of radioactive material and indicated that " Health Physics" responds very rapidly to their requests.
Two deliveries of radioactive material were reviewed. Both ~
shipments (February 2, and May'4,1982) were surveyed within
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-10-thirty minutes of arrival. No radiation or contamination in excess of the limits was observed.
t No items of noncompliance or deviations were identified in this area.
f.
Radwaste Training Based on review of records maintained by the training depart-ment, the Radwaste Supervisor, Radwaste Engineer, Radwaste Foreman, six radwaste technicians, three of four radwaste laborers have received the training described in Section XIV of Station Order S-A-126.
The fourth radwaste laborer had been recently assigned and was being scheduled to attend the training.
The inspector interviewed the Radwaste Foreman and two rad-waste technicians to evaluate the effectiveness of the training.
The interview included a discussion of each individual's responsibilities and several questions geared to their specific responsibilities. The inspector encouraged the individuals to use the station procedures, rules, regulations, or training material in responding to the questions.
Based on the interviews, the inspector concluded the training provided pursuant to S-A-126 was of a broad overview nature.
Discussions with the Training Specialist, review of " Radio-active Waste Packaging and Shipping Manual," Revision 0, dated September 22, 1981, and lessons plans supported the conclusion regarding the overview nature of the training. As a result of this inspection effort, the following observations for program improvement were presented to the licensee representatives at the exit interview:
10 CFR 71. Appendix E, criterion 6, states in part that
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procedures and instructions are reviewed, approved, distributed, and used at the location where prescribed activity is performed.
During the interviews, the inspector was informed by the radwaste technicians '. hat the radioactive material shipping procedure, S01-8.0 series were not available at the radwaste processing trailer until Wednesday June 16, 1982.
10 CFR 71, Appendix E, paragraph 2, states in part that the program shall provide for indoctrination and training of personnel to assure that suitable proficiency is achieved and maintained.
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-11-Although the technicians had received training pursuant to-S-A-126, they had not been trained in the radwaste shipping procedures and were unfamiliar with the content of those procedures.
No items of noncompliance or deviations were identified in this area.
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g.
Licensee Audit The inspector revievred Audit Report No. S01-45-82. This audit of radioactive waste shipments made from January 1,1981 through March 1982 was performed in the period May 3-11, 1982.
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The audit was performed in accordance with an inspection plan by a Quality Assurance Inspector familiar with radioactive material shipping requirements.
No Corrective Action Reports were generated as a result of this audit.
Field Surveillance Report H-205-81 and IPDR No. CIP-487 describing audits of activities performed by Torrey Pines
Technology for the licensee were also reviewed.
These audits followed the filter solidification program under development for the licensee.
No items of noncompliance or deviations were identifiad in this area.
5.
Exit Interview The inspector met with the-licensee representatives (denoted in paragraph 1) at the conclusion of the inspection on June 18, 1982.
The inspector summarized the scope and. findings of the inspection.
The licensee representative stated that the " Posting and Access Control" procedure will complete the review process and be implemented by June 30, 1982.
In view of the inappropriate analysis of' tritium activity described
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in paragraph 4.D., the inspector requested the Health Physics
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Manager on June 22, 1982 to perform a survey of. the equipment in l
which the tritium source had been used to determine if any evidence of leakage existed.
On June ~ 25, 1982, the Health Physics Manager advised the inspector that no indications of tritium leakage was i
found as a result of the survey.
As a result of reactive inspection effort involving LER No.82-017 described in paragraph 2 of this report, the inspector agreed to l
l discuss his understanding of Technical Specification 4.6 involving j
the need to sample the stack for iodine and particulate activity l
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with NRR and inform the Chemistry Supervisor of the results of that
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discussion. On June 22, 1982, after discussions with Mr. W. Pasciak, NRR, RAB, the inspector advised the Chemistry Supervisor that NRC
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understands Section 4.6 to require sampling the stack for iodine and particulate activity whenever that form of radioactive material is being released via that pathway.
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